fallout wiki Posted:

You can save Simms by killing Burke before he has a chance to fire at Simms. Mr. Burke is somewhat tougher than the average Wasteland human, so low-level characters may have trouble killing him in a single V.A.T.S. bumault (even using headshots), especially if using the 10mm pistol. This is easier to do if you attack Burke while the two are speaking. Burke does not target Simms immediately if you do this, and you receive no penalty for your rudeness. Simms will still thank you for saving him even though there was never an indication his life was in danger.